OSH Solutions LLChttp://oshsolutions.com
Solving Your Workplace Safety ChallengesSun, 01 Jan 2017 23:54:07 +0000en-UShourly1https://wordpress.org/?v=4.4.11A New Administration and What it Means for Regulatory Compliancehttp://oshsolutions.com/osh-solutions-2017/
http://oshsolutions.com/osh-solutions-2017/#respondSun, 01 Jan 2017 23:52:15 +0000http://oshsolutions.com/?p=676One of the questions on the minds of our clients is How will OSHA and other agencies change under a Trump Administration. Experience tells us that there are usually not any wholesale changes to specific regulations, but priorities tend to change. This is the case anytime there is a change in the U.S. Presidency from one political party to the other. Enforcement has been a priority for OSHA under President Obama. OSHA penalties have increased. A Severe Violators Enforcement Program was established. A greater emphasis on whistle blower cases has occurred. Employers, who in OSHA’s opinion, flagrantly violate regulations are publicly shamed through the use of press releases after inspections. This takes place before the employer is able to make its case with OSHA through informal hearings or the courts.

It can be reasonably anticipated that these measures will end or at least be greatly reduced under the Trump administration. Employers will receive greater assistance to create and maintain safe workplaces. Enforcement won’t stop, but will not be as emphasized or publicized by the OSHA. There will likely be a review of recently enacted regulations like the silica standard and changes to the general industry fall protection standard. Regulations will be reviewed to evaluate how much they contribute to employee safety compared with burdens placed on employers.

Looking at trucking safety enforcement, the new leadership within the Department of Transportation will evaluate recent regulations, but is not expected to initiate any major changes immediately. Infrastructure and trade deals will have a greater impact on the transportation industry than changes to the hours of service and speed limiting rules

In a September fact sheet, Trump targeted the FDA’s food safety program stating that “The FDA Food Police, which dictate how the federal government expects farmers to produce fruits and vegetables and even dictates the nutritional content of dog food,” the Trump campaign fact sheet complained.

“The rules govern the soil farmers use, farm and food production hygiene, food packaging, food temperatures and even what animals may roam which fields and when,” the fact sheet continued. “It also greatly increased inspections of food ‘facilities,’ and levies new taxes to pay for this inspection overkill.”

The fact sheet was quickly pulled from the website so we really do not know Trump’s current view on FDA food regulations.

Perhaps the greatest influence the Trump administration will have on FDA food safety regulations is through funding decisions. The FDA has maintained that they need a significant boost in funding to enforce the new regulations. It is not likely that the FDA will see the type of funding increase they claim is needed to run the program.

We don’t expect that our clients will notice a significant difference regarding what they need to do in order to be in compliance with OSHA, DOT (FMCSA) and FDA (FSMA and VFD) regulations. There will continue to be OSHA inspections, motor carrier truck inspections and occasional audits and we expect FDA will continue to move forward to regulate the animal food safety regulations. In our experience we have found that the employers who see value in safety and regulatory compliance beyond just meeting the requirements fare well under any administration.

]]>http://oshsolutions.com/osh-solutions-2017/feed/0FSMA for Animal Food Updatehttp://oshsolutions.com/fsma-animal-food-update/
http://oshsolutions.com/fsma-animal-food-update/#respondThu, 24 Mar 2016 12:28:42 +0000http://oshsolutions.com/?p=501What’s happening with FSMA? Here’s what we know. The compliance dates have not changed and thus far there has not been any word that the dates will be extended. Large firms (more than 500 employees) have about 6 months to come into compliance with the new current good manufacturing requirements. FDA’s guidance documents have yet to be released. It is expected that the documents will be completed sometime this summer. That doesn’t leave much time for the large firms to make use of the guidance information to prepare the procedures and guidelines that will meet the CGMP regulations.
Within the next year and one-half, those large firms will be required to have completed their hazard analysis, written their food safety plans and have implemented the steps to control significant hazards. The American Feed Industry Association is working with the University of Minnesota to identify known hazards in order to provide a starting point for mills to conduct their own hazard analysis. The Food Safety Preventive Controls Alliance (FSPCA) is also working on hazard analysis and has established a technical assistance network to help small to medium-sized companies with compliance questions and technical assistance.
The FSPCA is also tasked by FDA with developing the curriculum that lead trainers will use to train individuals to become Preventive Controls Qualified Individuals (PCQI). A PCQI is qualified through training or experience to conduct hazard analyses and to write the Food Safety Plan. It is expected that the training will offered starting in June, 2016.
Here are some steps you can take now to move toward compliance with FSMA.
1. Evaluate your housekeeping program. Is it working to keep your mill clean to the extent that you would be able to demonstrate to an inspector that animal food contamination will not occur as a result of poor housekeeping practices?
2. Evaluate your preventive maintenance program. Are preventive equipment and facility maintenance practices scheduled and can you show an inspector what your program includes and that the maintenance and inspection practices are being done?
3. Look at the Current Good Manufacturing Practices that your mill is currently required to follow. If your mill is licensed and registered as a medicated feed mill, there is a comprehensive set of CGMPs that you are already required to follow. If you manufacture medicated feed, but are not required to be licensed, you are required to meet a reduced set of CGMPs. The medicated feed mill requirements will still be enforced in addition to the new CGMPs required under FSMA.
4. Review the new CGMPs that will be required under FSMA. You will find that you are already complying with many of the practices, but may not have documentation to prove that you are in compliance. Procedures need to be implemented to meet the elements required within the CGMPs. This is what needs to be in place by mid September, 2016 for the large companies and by mid September, 2017 for most feed mills.
We don’t recommend heading to far beyond this point into the Hazard Analysis and Food Safety Plan part of the requirements until the guidance documents are released, hazards information is developed by the AFIA and others and the PCQI training begins.
OSH Solutions is here to help guide you through the process. Please let us know if you have any questions or would like assistance with any part of the steps listed above.
]]>http://oshsolutions.com/fsma-animal-food-update/feed/0Training that Works Part I – Why Don’t They Remember?http://oshsolutions.com/training-works-part-remember/
http://oshsolutions.com/training-works-part-remember/#respondWed, 02 Sep 2015 20:25:09 +0000http://oshsolutions.com/?p=435

Why don’t employees remember what is covered in safety training? Business owners express frustration when faced with the obvious fact that employees are not getting it. I have heard lawyers say documentation is so important, because employees will not remember having received training when being interviewed by an OSHA Compliance Officer or a lawyer as part of a deposition.

As a trainer and consultant, I am responsible to communicate safety practices effectively. The learning objective is to have employees consistently put the practices they learn to use. When that is not happening, there is a serious disconnect that must be addressed.

Have you ever noticed with new TV advertisements that a brand will often start with a longer ad and then shorten it as time goes on. The shorter message reinforces the message they expect was heard in the longer ad. Content can be reduced as repetition enables the message to sink in. Communicating safety practices is no different. The message must be clear, it must be memorable and it must be repeated often.

Stay tuned for our next blog when we will discuss a common safety strategy and why it often fails.

]]>http://oshsolutions.com/training-works-part-remember/feed/0OSHA Global Harmonization – Have You Met the Deadline?http://oshsolutions.com/osha-global-harmonization/
http://oshsolutions.com/osha-global-harmonization/#respondTue, 09 Jun 2015 12:51:07 +0000http://oshsolutions.com/?p=423We continue to hear from clients that they are not receiving Safety Data Sheets from their suppliers. Today is June 9 and the OSHA deadline for compliance with global harmonization system (GHS) requirements was June 1. Some suppliers are continuing to provide material safety data sheets and others haven’t prepared either an MSDS or SDS. Many have claimed that they have no idea about the new requirements. OSHA enacted the changes in 2012 and the first deadline for employee training was December 1. Companies had an additional 18 months after that date to comply with the bulk of the changes. So what gives?

I believe that some companies are being truthful in claiming they weren’t aware of the requirements. Not all companies are members of large trade organizations that monitor OSHA.activity. The day to day media may have had a story on it when OSHA first enacted the standard, but let’s face it, a new OSHA standard is not going to stay on the news cycle for much more than the time it takes to write the story.

Other companies believe that the requirements don’t apply to them. The term hazardous chemical is not normally associated with many of the materials that are used for work; such as spray paints, solvents, fuels and cleaners. Most people when they hear the word hazardous chemical are thinking about chlorine, anhydrous ammonia and hydrocloric acid for example. Tank cars and tank farms come to mind when the term hazardous chemical is used. Companies who were of the belief that they weren’t subject to the previous haz com rules probably don’t believe they need to comply with the new ones.

The new rules also captured many industries that were not subject to requirements for labels and/or safety data sheets in the past. Industries that process metals, plastics, and wood now need to address the hazards of dust created by these products when they create dust. Companies that handle grain or products with grain were also included in industries with the OSHA-defined dust explosion hazards. These companies face the reality that many of their suppliers have not developed SDSs to meet the compliance deadline.

There also are misunderstanding regarding a notice OSHA posted to its website in February regarding an extension of the deadline. OSHA was hearing from industry groups that members were not receiving the information they needed from upstream suppliers that they needed to write their SDSs. OSHA acknowledged the problem by agreeing to an extension for compliance to no later than December 1, as long as companies were making a good faith effort to obtain the information needed to develop SDSs. This is not an “oh great, we now can wait until December 1, 2015” extension. OSHA will be checking to make sure that information truly was not available. Companies need to periodically check back as part of their due diligence and good faith efforts.

. OSHA is in the process of developing a more extensive enforcement directive. In the meantime the agency has issues a new memorandum to replace the earlier one. This memorandum describes the actions OSHA expects to be taken for companies to prove its due diligence and good faith efforts. Here is a link to the OSHA Memorandum. Hazard Communications is a standard that is always on the list of top ten standard violations and we can expect that it will be pushing toward number 1 on that list once OSHA begins to enforce the standard.

Put it all together and it is easy to see why many companies who want to comply don’t have the information they need. Compliance with the Hazard Communications Standard, specifically the Safety Data Sheet and labeling requirement, means that each company is dependent on the action of many others to comply. I’m not certain that OSHA understands this well.

Here are a few steps you can take now to do your diligence should your efforts come into question during an OSHA inspection:

If you receive a shipment of products that are regulated under the Hazard Communications Standard and it does not have a proper label and safety data sheet, contact your supplier and let them know that you need this important safety information. Remind them of the June 1, 2015 compliance date.

Make sure you have a Material Safety Data Sheet for the product. An MSDS will still provide necessary safety information.

Check online to see if Safety Data Sheets are available for items you purchase in bulk.

Notify your suppliers that as of December 1, 2015 you will no longer be able to use their product unless it complies with applicable labeling and safety data sheet requirements.

Document your efforts and the responses you receive.

If your company is required to prepare labels and/or safety data sheets for products and your suppliers are not sending you the information you need to comply, be sure to do your due diligence and document efforts to receive this information. If feasible you should switch to a supplier that is complying. OSHA would expect this to be done. This will sort itself out in time. For now, do what you can to comply. Above all, don’t lose focus on what this should be about and that is providing safe conditions for your employees who handle hazardous chemical products.

]]>http://oshsolutions.com/osha-global-harmonization/feed/0GHS – Distributors Slow to Act … Do Your Parthttp://oshsolutions.com/ghs-distributors-slow-act-part/
http://oshsolutions.com/ghs-distributors-slow-act-part/#respondMon, 13 Apr 2015 12:19:54 +0000http://oshsolutions.com/?p=403There are now less than two months to go before the deadline when manufacturers or distributors of hazardous chemical products must change product labels and send Safety Data Sheets to their customers. Many companies are waiting until the due date before they provide these documents that are required by the U.S. Occupational Safety and Health Administration under its Hazard Communications standard. In fact, the website MSDS Online in and article titled: Compliance Alert-June 1st Deadline stated the following in the opening paragraph. “When OSHA revised the Hazard Communication Standard to align with GHS, it selected June 1, 2015 as the deadline by which chemical manufacturers and distributors were to complete the process of reclassifying hazardous chemicals and to have updated all safety data sheets and labels to GHS formats. MSDSonline believes it unlikely that all manufacturers and distributors will have completed this task by that date.” For the full article click here.

So what should an employer do? OSHA places responsibility on the manufacturer or distributor of the hazardous product to develop the Safety Data Sheet and provide it, and subsequent updates, at least one time to its customers. MSDS online recommends notifying your suppliers that you expect to receive a Safety Data Sheet by the June 1st deadline. I agree. From a compliance standpoint, your company will be the one who has to explain to OSHA why you do not have a Safety Data Sheet for a hazardous chemical at your workplace. It will go much more smoothly if you can show that you have attempted to obtain SDSs from your supplier. OSHA will follow up with the manufacturer if necessary.

If the June 1st date comes and you haven’t received a Safety Data Sheet for the product, you may choose to refuse shipment. One thing to keep in mind is that OSHA has given manufacturers up to December 1 of this year to clear their inventory of products that have MSDSs and old labels. It may be difficult to prove the source of the product. OSHA also encourages you to notify the agency if you are not getting cooperation from a distributor.

In the scope of its standard OSHA states the following:

“This section requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training. In addition, this section requires distributors to transmit the required information to employers. (Employers who do not produce or import chemicals need only focus on those parts of this rule that deal with establishing a workplace program and communicating information to their workers.)” Emphasis added.

With that in mind, two steps employers need to take now include updating your Hazard Communications Written Plan to reflect the new requirements and to provide training to employees. Training on the new system was to be done by December 1, 2013. These are employer responsibilities that OSHA will evaluate during an inspection.

We will continue to monitor this and let you know by mid May if anything has changed. In the meantime, be sure to do your part to make sure employees understand how to work safely with hazardous chemicals. Update your written program and train your employees.

]]>http://oshsolutions.com/ghs-distributors-slow-act-part/feed/0Taking the “Near Miss” Seriouslyhttp://oshsolutions.com/near-miss/
http://oshsolutions.com/near-miss/#respondSun, 08 Feb 2015 18:30:52 +0000http://oshsolutions.com/?p=398The one that almost happened. We’ve all had them. Maybe it was a near wreck while driving. Maybe it was a part that broke and almost hit you. Maybe it was the pedestrian that you almost hit while backing up the forklift. Near misses happen often and are a call to action to take steps that can prevent the real thing from happening.

In a distracted driving video I recently viewed, the main character, the guy who plowed into the vehicle in front of him while reading a text message, talks about how he had a number of near misses while texting. Unfortunately, his failure to heed the near miss led to a death, jail time and lives forever changed.

I remember bumping into the car in front of me while merging from one road onto another several years ago. I was looking back to see if it there was any traffic and accelerated without looking ahead to see if the driver ahead of me was moving forward too. Fortunately, there was no one was hurt and there was no damage to the vehicles. That incident was set up by a number of close calls where I was able to stop in time. I remember saying to myself after a few of those “near misses” one day you won’t be so fortunate and you will hit someone. I have been much more attentive in my driving since the accident.

Safety professionals encourage near miss reporting in work places. We recognize that many near misses occur before an accident and that if we pay attention to near misses, we can prevent accidents from occurring. Simply stated, a near miss should be reported and investigated just as you would investigate an accident. Determining causation leads to identifying and establishing control measures to prevent the real thing from happening.

It is important for management to let employees know that near miss reporting is expected and valued. More important is that employees need to know that they can report near misses without fear of disciplinary action. This is one program that needs to be kept positive with a clear sense of purpose. The goal is to prevent an accident that involves property damage or injury. A near miss is neither of those things, it is something that could have led to those things happening. If fear of discipline is an issue, employees will not report near misses.

One of the things I look for when evaluating safety programs is the presence of a near miss reporting system. When near misses are being reported, it is a strong indicator of a solid safety culture where the fundamentals are in place. It is often the last big hurdle to achieve in the process of putting that culture together. It is a sign of mutual trust and respect between management and workers.

I encourage you to take steps to implement a near miss reporting and investigation process. Write a near miss reporting policy. Develop a near miss investigation form. Much of it will be similar to an accident investigation form. Train your supervisors on the program and to encourage reporting. Train your employees to identify near misses when they occur and that they can feel free to report them without fear of reprisal. Work together to implement and maintain the program.

Near misses are the caution sign on the way to an accident. By taking near misses as seriously as accidents, we can prevent accidents.

]]>http://oshsolutions.com/near-miss/feed/0OSHA Record Keeping and Injury Reportinghttp://oshsolutions.com/osha-record-keeping-injury-reporting/
http://oshsolutions.com/osha-record-keeping-injury-reporting/#respondMon, 02 Feb 2015 01:40:19 +0000http://oshsolutions.com/?p=393If you are required to maintain an OSHA 300 log of recordable injuries and illnesses, you must post the 300 A Summary sheet by February 1, 2015. It should be posted in an area where your employees will be able to see it. You must keep it posted until April 30, 2015. Be sure to post only the 300 A form and not the 300 log itself.

The only companies that are not required to use the OSHA 300 log are those with ten or fewer employees at all times throughout the year. This is not a full time equivalent number and even a part-time employee counts as one employee. The other exemption is for those companies that are in low hazards industries as determined by OSHA. For the list of low hazard industries check out this link. OSHA added new industries to the recordkeeping requirement at the end of last year. These companies will be required to record injuries on the log starting this year. Here is a link to that list.

If you are not exempt, you must record work-related injuries and illnesses. OSHA developed an excel workbook that contains all of the forms needed to fulfill this requirement. The link to the workbook is found here. Not all work-related injuries and illnesses must be recorded and OSHA has a guide at the record-keeping page on the www.osha.gov website.

The first thing OSHA will usually ask to see when they arrive for an inspection are the OSHA logs. Be sure to keep five years plus the current year on file. If the logs show that there have been low rates of injuries, especially those that result in lost work time or other restrictions, OSHA will often leave and will not conduct an inspection. The logs must be accurate and complete.

Another change OSHA made towards the end of 2014 regards the requirements to report injuries to OSHA. Here is the updated requirement. All work-related fatalities must be reported to OSHA within 8 hours of finding out about it. All inpatient hospitalizations, amputations or injuries involving loss of an eye must be reported by the employer within 24 hours of learning about it. OSHA’s reasoning behind this change was to capture information about the more serious injuries that take place at work and to be able to respond and investigate those injuries.

Two significant changes at the start of a new year. Please let us know if we can help with any questions or resources you may need.

]]>http://oshsolutions.com/osha-record-keeping-injury-reporting/feed/0GHS – Globally Harmonized Systemhttp://oshsolutions.com/ghs-globally-harmonized-system/
http://oshsolutions.com/ghs-globally-harmonized-system/#respondFri, 02 Jan 2015 09:22:40 +0000http://oshsolutions.com/?p=361This is the year when most regulations of OSHA’s Global Harmonization of the Hazard Communications Standard takes effect. Manufacturers of hazardous chemicals are required to use new labels and to provide safety data sheets by June 1, 2015. Those who use hazardous chemicals in the workplace are to have trained employees on the Globally Harmonized System (GHS) of hazard communications by December 1, 2013. Are you currently in compliance and will you be ready to meet your company’s other obligations under the standard by June 1, 2015?

If you want a more detailed explanation of GHS see this post

If you provided training to employees ahead of the December 1, 2015 date you are one step ahead of many companies. Lack of training was the number one cited issue under Haz Com standard citations last year. Please remember that employees hired after your initial training session also need to be trained. In fact, you may want to think about providing a training session for everyone this year prior to the June 1 date. You will be able to provide specific examples of proper labeling and safety data sheets for products your employees use. This will help increase the awareness level of your employees for handling hazardous chemicals.

Don’t complicate the training. The main areas to address under the new rules involve: 1) the use of pictograms to symbolize hazards on the labels and 2) the new required format for Safety Data Sheets. Many elements of the hazard communications standard remain the same. These two areas should be the focus of your training for those who have received hazard communications training in the past. There are many resources for training materials. Check out our resource page for links to the OSHA website, Northwest Independent Contractors Association and other sites with safety training materials.

If you manufacture chemicals that are classified as hazardous under the globally-harmonized system, you most-likely are in the process of determining the label information you will need to provide on your products as well as developing new safety data sheets for those products. If you are still looking for direction on this, here is a link to the OSHA document that outlines the system including hazard classification, label requirements and the safety data sheet format.

Under the OSHA regulations, combustible dust is considered a physical hazard even though it is not classified specifically as hazardous under Global Harmonization. This means that if you manufacture a product that in and of itself constitutes a dust hazard or if it creates a combustible dust when processed i.e. certain metals, plastics, wood or grain you are subject to labeling and safety data sheet requirements. We will be watching for guidance from various industry groups over the next few months to help companies understand how they are expected to meet these requirements. There have been some letters of interpretation posted on the topic. You can find the letters at this link.

As your company begins to receive Safety Data Sheets, be sure to update your safety data sheet binders or other system with this new information. Old material safety data sheets should be retained for 30 years or in the alternative you are required to maintain a list of each chemical used and when and where it was used. This must be maintained for 30 years.

Workplace container labeling requirements are not to take effect until June 1, 2016. We will address this topic more fully in another post.

The format for a written program remains similar to what OSHA has required in the past. Main changes are to reference the new labeling requirements (pictograms) and safety data sheets versus material safety data sheets. The small entity guide referenced at the end of this blog contains a sample written program.

GHS is here to stay and will impact nearly all businesses in some manner during the first part of 2015. Make use of the resources already mentioned. Another helpful publication is OSHA’s Small Entity Compliance Guide. The guide is a helpful resource that will guide businesses through the process of establishing a hazard communications program that meets the new GHS requirements.

Globally Harmonized System

]]>http://oshsolutions.com/ghs-globally-harmonized-system/feed/0What does GHS stand for and how does it impact me?http://oshsolutions.com/ghs-stand-impact-me/
http://oshsolutions.com/ghs-stand-impact-me/#commentsThu, 01 Jan 2015 16:30:52 +0000http://oshsolutions.com/?p=368
GHS is an acronym that stands for Globally Harmonized System of Classification and Labeling of Chemicals. It has a general self explanation in terms of what it is used for, but there is a bit more of an in depth meaning as well. A GHS is designed in cooperation with multiple nations and authorities to help classify chemicals and ensure that safety data sheets, or SDSs are maintained. In many countries, all chemicals classified under the GHS would require to be maintained with a SDS. The sheet contains vital information about the chemical, as well as what procedures to follow for safe usage, disposal and emergency care if exposure occurs.

The GHS is often incorporated into national and local standards.

Since its development by an international team of experts, the GHS has been able to help develop clear systems for regulations. It has also improved many other industrial and trade circumstances, wherein proper transportation has been employed for various chemicals. Precise precautions have helped reduced not only costs in transportation, but have also helped ensure more prompt response and treatment during accidental exposure. The GHS encompasses all chemicals that may possible be found in: everyday and industrial workplaces, used in transportation, pesticides, medications, and consumer products. If there is any potential for living interaction with a commercial chemical, it is assigned a hazard rating under the GHS.

The benefits of the Globally Harmonized System are intended for everyone.

For manufactures the maintenance of proper labeling and and SDS have ensured the safety of all people involved. Many people who have ever worked in the cleaning or industrial industry are already familiar with Globally Harmonized System training, even if the do not realize it. It may be referred to as GHS or SDS training, or is simply called safety sheets training in come organizations. No matter the reference used, is a requirement that people who will be working with any type of chemical be properly trained and made aware of how to understand the label and SDS. Employers can use paid for, constructed training modules, or access free online power points and presentations regarding the GHS. The global acceptance of the GHS to date includes: The Unite States, Canada, Europe, Australia, and many more totaling 67 major countries worldwide. This indicates that that around 35% of the world utilize the GHS.

]]>http://oshsolutions.com/ghs-stand-impact-me/feed/1OSHA Haz Com Globally Harmonized System Updatehttp://oshsolutions.com/osha-haz-globally-harmonized-system-update/
http://oshsolutions.com/osha-haz-globally-harmonized-system-update/#respondWed, 17 Dec 2014 11:44:38 +0000http://oshsolutions.com/?p=338December 1, 2014 marks one year from the date that employees were to be trained in OSHA’s addition of the Globally Harmonized System for Hazard Communications to its Haz Com Standard. Have all of your employees received training? Yes, it was a bit premature of OSHA to require training by the end of 2013 for something that wasn’t required until mid 2015. Now that we are less than a year away from implementation of major requirements, it makes sense to train your employees now. If you provided training early in 2013, you should consider providing refresher training.

We expect that manufacturers of hazardous chemicals will soon begin labeling their products using the required text and pictograms, and to release new Safety Data Sheets (SDSs). A year ago I spoke with an OSHA Compliance Safety and Health Officer who noted that she was beginning to see consumer products with pictograms on the labels. Since then there has not been a great increase in labeling and the publication of SDSs. In fact a search of major companies websites shows that, in many cases, MSDSs have yet to be replaced with SDSs.

Most likely, companies have held off on new labels and safety data sheets until 2015 to incur costs relating to the changes closer to the time they are required to do so. Prudently, they also want make sure they don’t have to respond to any last minute changes by OSHA. That certainly makes good business sense. Since no last minute changes are anticipated, we can expect manufacturers and importers to begin moving to compliance during the first quarter of 2015.

Hazard Communications remains the number two most violated OSHA standard. You can expect that citations will increase over the next few years. Training is just one part of the program, but it is the one thing that is required as of today. Make sure your employees understand OSHA’s changes to its Hazard Communications Standard.